NPDES Permit No.: AR , ARR00A412

Transcription

1 July 7, 2011 Donnie Pretty Acme Brick Company- Perla Facility 3024 Acme Brick Plaza Fort Worth, Texas AFIN: NPDES Permit No.: AR , ARR00A412 Dear Mr. Pretty: On June 16, 2011, I performed a Compliance Sampling Inspection (AR ) and an Industrial Stormwater Inspection (ARR00A412) of the waste water treatment facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violations: AR There is excessive vegetation around the wastewater lagoons. The root structure of the trees and brush can weaken the levees and penetrate the pond liner. Additionally, trees and brush offer habitat to burrowing animals. This vegetation needs to be removed and the levees need to be repaired. This is a violation of Part III.B.1.a of the permit. 2. The levees contain some low spots and erosion that needs to be repaired. This is a violation of Part III.B.1.a of the permit. ARR00A412 There were no deficiencies noted during this inspection of the Industrial Stormwater permit. It was observed though that no storm event sample has been taken as of this year. This sampling must be completed by the end of this month. In the future it is advised that you need to develop a plan to complete this sampling earlier in the year in order to meet your sampling requirements.

2 Donnie Pretty, Acme Brick July 7, 2011 Page 2 The above items require your immediate attention. Please submit a written response to these findings to the Water Division Enforcement Branch Manager. This response should be mailed to the address below, or ed to Water-Enforcement- Report@adeq.state.ar.us<mailto:Water-Enforcement-Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentations (i.e. photos) is due by June 17, If I can be any assistance, please contact me at Sincerely, Dawn Keller Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch

3 Form Approved OMB No Approval Expires UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R R 0 0 A W 19 S 20 2 Remarks A F I N H O T S P R I N G Inspection Work Days Facility Evaluation Rating BI QA Reserved N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Acme Brick- Perla Facility Hwy 67 North of Malvern, AR Entry Time/Date 8:30 a.m. on 06/16/2011 Exit Time/Date 9:40 a.m. on 06/16/2011 Permit Effective Date 12/10/2010 Permit Expiration Date 06/30/2014 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Todd Thornton/HR Manager/ ext. 227 Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Donnie Pretty Acme Brick Company- Perla Facility 3024 Acme Brick Plaza Fort Worth, Texas Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) N Permit N Flow Measurement S Operations & Maintenance N Sampling S Records/Reports S Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention S Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory S Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) There were no deficiencies noted during this inspection of the Industrial Stormwater permit. It was observed though that no storm event sample has been taken as of this year. This sampling must be completed by the end of this month. In the future it is advised that you need to develop a plan to complete this sampling earlier in the year in order to meet your sampling requirements. Name(s) and Signature(s) of Inspector(s) Dawn Keller/ Agency/Office/Telephone/Fax AR Dept. of Environmental Quality- Date 06/16/2011 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date

4 Inspection Form Legend: S = Satisfactory, M = Marginal, U = Unsatisfactory, Y = Yes, N = No, NI = Not Implemented, NA = Not Applicable, NE = Not Evaluated If Y and a NI are check it means it is in the SWPPP but not implemented in the field which is a violation. SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS 5. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 6. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 7. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 8. ALL DISCHARGES ARE PERMITTED: Y N NA NE Comments: SECTION B: STORM WATER POLLUTION PREVENTION PLAN EVALUATION PERMITTEE SWPPP MEETS PERMIT REQUIRMENTS 1. Is the SWPPP available for review by ADEQ? (Part 4.2) 2. Does the SWPPP contain facility name, general permit tracking number, facility physical address, and SIC and NAICS codes? (Part 4.6.1) 3. Pollution Prevention Team A. Does the SWPPP identify specific individuals or positions?(part 4.6.2) B. Does the SWPPP outline the responsibilities of each member of the Pollution Prevention Team? (Part 4.6.2) 4. Does the SWPPP contain a facility description (process diagram, general layout, storage of raw materials, the flow of goods and materials through the facility and seasonal variations)? (Part 4.6.3) 5. Does the facility site map contain the following items? A) The size of the property in acres? (Part a) B) The location and extent of significant structures and impervious surfaces? (Part b) C) The direction of stormwater flow using arrows? (Part c) D) The locations of all existing structural control measures? (Part d) E) The locations of all receiving wasters in the immediate vicinity of the facility? (Part e) F) The locations of all stormwater conveyances including ditches, pipes, and swales? (Part f) G) The locations of potential pollutant sources? (Part g) H) The locations of all stormwater monitoring points? (Part h) I) The locations of stormwater inlets and outfalls with unique identification code for each outfall with indications if one or more outfall is being treated as substantially identical and an approximate outline of the areas draining to each outfall? (Part i) J) Where the stormwater discharges to municipal separate storm sewer system (MS4), if applicable? (Part j) K) The locations and descriptions of all non-stormwater discharges identified in the SWPPP? (Part k) L) The locations of the following activities if they are exposed to precipitation? (Part l) Fueling Stations Vehicle and equipment maintenance and/or cleaning areas Loading and unloading areas Locations used for the treatment, storage, or disposal of waste Liquid storage tanks Processing and storage areas Immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-byproducts used or created by the facility Transfer areas for substances in bulk Machinery M) The locations and sources of run-on to the site from adjacent property that contains significant quantities of pollutants? (Part m)

5 6. A description of potential pollutant sources A) An inventory of industrial activities which have been or may potentially be sources of significant amounts of pollutants? (Part ) B) An inventory of all types of materials handled at the site that might potentially be exposed to precipitation? (Part ) C) A list of significant spills and significant leaks of toxic or hazardous pollutants that have occurred in areas exposed to precipitation or drained to a stormwater conveyance for three years prior to the effective date of the permit. (Part ) D) A summary of existing discharge sampling data (Part ) E) Risk Identification and Summary of Potential Pollutant Sources (Part ) 7. Measures and Controls SWPPP must describe how these are used. A) Best Management Practices (BMPs) (Part ) B) Exposure Minimization (Part ) C) Good Housekeeping (Part ) D) Preventative Maintenance (Part ) E) Spill Prevention and Response Procedures (Part ) F) Employee Training Procedures (Part ) G) Erosion and Sediment Control (Part ) H) Management of Run-on and Runoff (Part ) I) Additional Requirements for Salt Storage (Part ) 8. Authorized Non-stormwater Discharges (Part 4.6.7) list must be in SWPPP 9. Evaluations and Inspections (Part ) A) Visual Site Inspections (minimum 4/year) (Part ) At least one visual inspection conducted during a rain event Inspections recorded and include: date of inspection, person doing inspection; major observations, and corrective actions required. B) Comprehensive Site Compliance Evaluation (Annual) (Part ) Comments:: SECTION C: MONITORING PERMITTEE MONITORING MEETS PERMIT REQUIRMENTS 1. Is the facility one of the four Effluent Guideline Facilities in the Permit? (Cement MFG, Fertilizer MFG, Steam Electric coal pile, or Paving and Roofing Materials)(Part 3.1.1) A) Are all outfalls from the regulated process being sampled? (Part 3.1.3) B) If coal pile run off is monitored, are all other stormwater flows excluded? (Part 3.1.1) 2 Which of the monitoring categories is this facility subject to: (Part 3.3) A) Are samples being collected for each semi-annual monitoring period (Part 3.5) B) Are samples being collected from the location specified in the NOI and SWPPP (Part 3.6) C) Has the permittee determined that some of the outfalls are similar? (Part 3.7.1) Are the conditions on the ground still the same as documented for the similar outfalls (Part 3.7.1) D) Are all parameters for the monitoring category being sampled and analyzed? (Part 3.7.2) E) Were the samples collected during a measureable storm event? (Part b) F) Were the samples properly preserved and analyzed? (Part 3.7.2) G) Are the sample locations suitable for the collection of a representative sample? (Part 3.3) 3. Has any of the monitoring revealed an exceedance of the benchmark values for this facility?(part ) A) Has a process to develop a corrective action plan been started within 30 days of exceedances? (Part ) B) If four monitoring periods have passed without an exceedance of a benchmark value, has the permittee requested a reduction in monitoring? (Part )

6 SECTION D: RECORD KEEPING AND REPORTING PERMITTEE RECORD KEEPING AND REPORTING MEETS PERMIT REQUIRMENTS 1. Have DMRs for the previous year of monitoring been submitted to ADEQ and is a copy in the file? (Part a) Are the DMRs properly completed? Does the permittee have copies of lab reports and chain of custody records? Are the appropriate records of the measureable storm event and sampling being kept? (Part e) 2. Has a copy of the annual comprehensive evaluation been submitted to the agency and is a copy on file? (Part b) 3. Is permittee keeping copies of inspections and corrective actions on file? (Part ) 4. Are copies of training records being kept on file? (Part ) 5. Is there a list of significant spills and leaks being maintained? (Part ) Comments: This is the first sampling period for this permit. Samples had not been obtained as of this inspection. SECTION E: FACILITY TOUR PERMITTEE FACILITY TOUR MEETS PERMIT REQUIRMENTS 1. Any evidence of spills or leaks that have not been properly cleaned up as required by the SWPPP? 2. Any evidence of erosion or un-stabilized ground? 3. Any controls, structures, or storage areas that are not as identified in the SWPPP? 4. Any non-stormwater discharges not identified in the SWPPP? (see Part 1.7 of permit for list of allowable non-stormwater discharges) 5. Any non-stormwater discharges that are not allowed under this permit? (see Part 1.7 of permit for list of allowable non-stormwater discharges) 6. Are BMPs being properly operated and maintained? (Part 6.1) 7. Are housekeeping procedures being implemented and are they sufficient? Comments: